On Friday afternoon, the CFTC published Release 9146-25, a document with a long title and a simple message: Bitcoin, Ethereum, and USDC are getting a supervised trial run as collateral inside the US derivatives system.
It’s an experiment with guardrails, reporting, and plenty of fine print, but it represents a real shift in how the agency wants Americans to trade crypto: onshore, supervised, and with fewer hoops between the assets people hold and the markets where they hedge.
The move arrives alongside another milestone: the CFTC has cleared the path for spot crypto products to list on its registered exchanges for the first time.
Put the two together, and the direction becomes obvious. Instead of pushing crypto to the fringes of the financial system, the agency is now testing ways to plug it directly into the same pipes that run futures and swaps.
How collateral works (and why you should care)
To understand why the pilot matters, you have to understand collateral in the simplest possible terms. Imagine a derivatives trade as two people making a bet in a room watched by a referee. Because the bet can go wrong fast (prices jump, someone misjudges a move), the referee insists that both people hand over something valuable upfront.
That something valuable is collateral. It’s there to make sure that if the market flips, the referee can settle the bet without chasing anyone down the hallway.
In the real world, that referee is a clearinghouse. The people making the bets are traders. And the one collecting collateral from customers is a futures commission merchant (FCM), a sort of high-security middleman that lives between traders and the clearinghouse.
Until now, FCMs have been encouraged to demand dollars or Treasuries for most trades because those assets behave predictably. Crypto never made the list because it was too volatile, had excessive custody complexity, and raised too many unanswered legal questions.
Release 9146-25 effectively changes that. It outlines how tokenized assets can be used as collateral, the controls firms need, and which digital assets qualify for the pilot. The list is intentionally short: Bitcoin, Ether, and one regulated stablecoin, USDC. It’s crypto getting a supervised backstage pass.
What’s actually in Release 9146-25?
The document is split into two key pieces: a digital-assets pilot program and a no-action letter for FCMs.
The pilot program is the big headline. It provides exchanges and clearinghouses with a set of rules for how tokenized assets, including BTC, ETH, USDC, and tokenized Treasuries, may be used for margining and settlement.
Everyone involved must prove they can control the wallets, safeguard customer assets, value everything correctly, and keep proper books. It’s less “freewheeling innovation” and more “show us you can run this without breaking anything.”
The no-action letter is the practical counterpart. It authorizes FCMs to accept those same assets as customer collateral for a limited period, under strict conditions.
It also replaces old guidance that effectively told brokers to keep “virtual currencies” away from customer segregation entirely. That guidance made sense in 2020, but it makes less sense now, in a world where tokenization is moving into mainstream finance.
A few details matter for understanding how the pilot will work:
- The first three months are restricted. In the opening phase, FCMs can accept only BTC, ETH, and USDC as margin. That short list is deliberate, as the agency clearly wants a clean dataset before expanding the scope.
- Reporting is constant and granular. FCMs must report weekly the exact amounts of crypto they hold for customers and where those assets sit. This gives the CFTC an early-warning system if something breaks.
- Everything must be segregated. Crypto posted as margin must sit in properly segregated accounts, meaning customer assets are kept away from the company’s assets and creditors. The wallets must be legally enforceable, accessible, and auditable.
- Haircuts will be conservative. Because crypto fluctuates more than Treasuries, the value counted toward margin will be discounted. This is how regulators offset volatility without banning the asset outright.
- The pilot is temporary. The CFTC hasn’t announced a firm end date, but pilots typically last one to two years. The agency will want enough time to observe stress events, smooth periods, sharp rallies, and dull weeks.
During that period, the CFTC will gather data that the old advisory structure could never provide: how crypto collateral behaves in normal markets, how fast volatility eats into margins, how stablecoins behave when they back leveraged positions, and whether firms can actually manage wallet-level controls without stumbling.
Who joins first?
Some firms are already positioned to move quickly. Crypto.com, which runs a CFTC-registered clearinghouse, told the agency it already supports crypto-based and tokenized collateral in other markets and can adapt those systems domestically.
Other likely candidates include LedgerX’s owner, the crypto-native trading firms that work with CME’s bitcoin futures, and any FCM that has already built wallet infrastructure for institutional clients.
Traditional brokers may take longer. They are cautious by design, and many have never managed on-chain customer assets before. But the reward is clear: new customers who want a regulated platform that can accept crypto directly, without forcing conversions into dollar cash piles.
Stablecoin issuers also have something at stake. USDC’s inclusion gives Circle a strong signal that the token’s regulatory architecture aligns with the requirements of the derivatives system. Tokenization companies that wrap Treasuries will read this as an invitation too, although they’ll face steeper custody and legal scrutiny.
What changes for traders?
The practical effects will show up in how traders fund positions.
Take a hedge fund running a Bitcoin basis trade. Today, it may hold BTC in one place and dollars at an FCM in another, constantly moving money back and forth to support futures margin. In the pilot system, it can keep more of that value in BTC and post it directly as margin.
That reduces friction and cuts the number of conversions needed to keep the trade running.
Or consider a miner hedging next quarter’s production. Instead of selling BTC for dollars just to meet margin calls, it can use current holdings to back a listed contract. That keeps more activity onshore and reduces the need for offshore leverage.
Retail users won’t feel the change immediately. Most retail platforms sit on top of FCMs, and few will rush to accept volatile collateral from small accounts. But once large brokers adopt the system, and once the CFTC gathers enough data to expand the pilot, retail interfaces could start offering “use your BTC balance as margin” toggles.
The bigger picture
For years, offshore platforms attracted Americans with a simple promise: bring your crypto, use it as collateral, and trade around the clock. US venues couldn’t match that experience under existing rules, and liquidity flowed to places regulators couldn’t or wouldn’t see.
The CFTC isn’t trying to recreate offshore markets onshore. It’s taking a methodical approach and testing whether crypto collateral can sit inside the US system without compromising customer protection, clearinghouse stability, or market integrity.
If the experiment works, the agency gets a playbook for permanent integration. If it goes poorly, it has the reporting and supervisory levers to shut the door just as quickly.
Release 9146-25 acknowledges that the market already uses these assets for leverage and hedging, and that ignoring that reality only pushes risk into darker corners. The pilot brings that activity into view, lets the CFTC measure it, and offers firms a supervised path to modernize their collateral operations.
If the next year produces clean data and no crises, US traders may finally get something they’ve asked for since the first regulated bitcoin future launched: the ability to trade onshore without leaving their assets behind.
